Publication date: July 07, 2026
| The draft Act of April 13, 2026, amending the Act on Food and Nutrition Safety will enter into force six months after its publication. The new regulations primarily impact producers, importers, distributors, and sellers of dietary supplements – both in traditional and online channels. Below, we present the real changes to your business. |
Every dietary supplement introduced to the market for the first time must be reported to the Chief Sanitary Inspector (GIS). Until now, various forms were acceptable – paper or electronic, with a handwritten or electronic signature. After the amendment comes into effect, the only acceptable method will be the e-Sanepid platform.
What does this mean in practice?
The change also concerns the timing of the notification obligation: the previous option to notify the Chief Sanitary Inspectorate (GIS) at the stage of intended product introduction is no longer available. The obligation now arises at the time of actual introduction to the market.
The amendment introduces a completely new mechanism for conducting investigations. This change has the greatest potential to surprise companies without effective internal compliance procedures.
If the Chief Sanitary Inspectorate initiates an investigation and requests the entity to submit a scientific opinion, the company has exactly 14 days to submit an application to an accredited scientific unit – at the same time forwarding a copy of it to the Chief Sanitary Inspectorate.
| Step | What’s going on |
| 14 days | Deadline for submitting an application for a scientific opinion to a scientific unit (from the date of delivery of the request by GIS) |
| 6 months | Maximum time for a scientific unit to issue an opinion |
| Up to 12 months | Possible extension of the deadline by the entity if the case is complex |
| Failure to meet 14 days | Automatic presumption that the product is incorrectly classified and does not meet the requirements – GIS ends the proceedings to the detriment of the entity |
The mechanism for presuming irregularities is a significant innovation. Previously, a company’s inaction during the proceedings did not automatically result in any legal consequences – the proceedings could drag on for years. Following the amendment, any failure to meet the 14-day deadline will lead to direct negative consequences, regardless of whether the product is safe.
| The ban on re-registration – an important trap |
| Once the investigation is complete, the entity cannot submit a new notification for a product with the same qualitative and quantitative composition. If the company withdraws its notification during the investigation, this prohibition is indefinite. In such cases, changing the composition may be the only way to return to the market. |
This change directly impacts brands engaging in active digital marketing. Previously, advertising or presenting a dietary supplement without prior notification to the Chief Sanitary Inspectorate (GIS) was punishable by a fine (a misdemeanor). Following the amendment, this becomes grounds for imposing an administrative fine – with new, significantly higher penalties.
The amendment penalizes not only the sale of a supplement without reporting it to the Chief Sanitary Inspectorate (GIS), but also the mere advertising or presentation of it if the notification has not been effectively submitted. In other words:
| Key: What is a “successful report”? |
| The notification is effectively submitted when the company receives official confirmation of receipt from the e-Sanepid platform. Simply submitting the form isn’t enough – confirmation is what counts. These dates can differ by several days or more. Every marketing campaign should be planned with this time buffer in mind. |
The amendment expands liability for violations of advertising requirements from labeling to the entire marketing message. Previously, sanctions primarily covered incorrect packaging labeling. Following the amendment, a company is responsible for every communication channel – online advertising, point-of-sale materials, newsletters, or YouTube videos – if the message suggests that a varied diet does not provide sufficient nutrients, or if a supplement is presented as a medicinal product.
The Chief Sanitary Inspectorate (GIS) has maintained a register of dietary supplements before, but the amendment will significantly expand its scope and availability. The data will be published on the e-Sanepid platform and will include:
| Reputational risk before final decision |
| Information about the initiation of an investigation will appear in the public register immediately – not after the proceedings have concluded. Consumers and competitors will have access to this information before the Chief Sanitary Inspectorate issues any ruling. Even if the proceedings end favorably for the company, the registry record could impact brand perception. |
The maximum administrative fine for violating food safety regulations is increasing from 30 to 100 times the average monthly salary. At the current salary level, this means:
| Before the amendment | After the amendment | |
| Multiplier | 30× | 100× |
| Maximum penalty | approx. PLN 245,000 | approx. PLN 818,000 |
The new penalties are imposed administratively (not as fiscal or misdemeanor offenses), which means faster proceedings and no need to prove intentional guilt. A mere finding of a violation is sufficient. The increased level of sanctions has a real deterrent effect, especially for companies with turnover in the tens of millions of zlotys.
| Risk area | Triggering situation | Consequence |
| Advertising before submission | Launch of the campaign on social media before the official confirmation of receipt of the notification by the Chief Sanitary Inspectorate | Fine up to approximately PLN 818,000 |
| Exceeding the 14-day deadline | No application submitted to the scientific unit within 14 days of the request by the Chief Sanitary Inspectorate | Automatic presumption of product irregularity; termination of proceedings to the detriment of the entity |
| Errors in the product description on the website | Content suggesting medicinal properties or claiming that a diet without a supplement is insufficient | Fine of up to approximately PLN 818,000; risk of product recall |
| Publicity of the proceedings | Initiation of explanatory proceedings by GIS | Immediate publication of information in the public register – reputational damage before resolution |
| Sale without notification | Distribution to wholesalers or stores before effective notification of the Chief Sanitary Inspectorate | A fine of up to approximately PLN 818,000; possible ban on further trading |
| No trusted profile/signature | The employees responsible for reporting do not have the required qualifications | Notification submitted ineffectively – risk of sanctions as for failure to notify |
| What is worth doing before the regulations come into force? |
| 1. Register on the e-Sanepid platform |
| Ensure that at least two people in your company have a qualified electronic signature or an active trusted profile. Register a company account on e-Sanepid before the law comes into effect and complete a test application. A lack of technical readiness on the date the regulations come into effect could prevent you from legally introducing new products to the market. |
| 2. Audit current submissions and the new product calendar |
| Check that all products in your offer have successfully submitted notifications to the Chief Sanitary Inspectorate. For products planned for launch in the coming months, submit notifications well in advance of the planned sale date or marketing campaign. Take into account the waiting time for official confirmation of receipt. |
| 3. Implement a procedure for monitoring deadlines in explanatory proceedings |
| Designate a person responsible for receiving correspondence from the e-Sanepid platform and immediately forwarding documents to legal or compliance services. The 14-day deadline for submitting a request for a scientific opinion is short—missing it automatically creates a presumption of irregularities. It’s worth identifying accredited scientific institutions now with which the company could quickly establish cooperation if proceedings are initiated. |
| 4. Verify all marketing materials – websites, social media, product descriptions |
| Analyze the content on your website, online store, social media profiles and sales materials for: |
| suggestions for medicinal or therapeutic properties of supplements, |
| information suggesting that a normal diet does not provide adequate nutrients, |
| promoting products for which the GIS notification has not yet been successfully submitted. |
| Influencer marketing campaigns deserve special attention – messages created by third parties still place the responsibility on the company commissioning the campaign. |
| 5. Monitor the GIS register and respond to information about proceedings |
| Once the expanded SEPIS register is launched, regularly check the status of your products. If you receive information about the initiation of an investigation, act immediately. Inaction at this stage can lead to automatic assumptions of irregularities and reputational damage that will be publicly visible throughout the proceedings. |